Develop and implement a policy that clearly defines roles and responsibilities for Office of Multifamily Housing Programs’ staff for EBLL-related requirements, including the oversight of property owners’ compliance with these requirements.

Establish processes to track reported EBLLs for the Office of Multifamily Housing Programs to easily identify the status of owners’ remediation efforts for units that were the source of the confirmed EBLL.

Housing should refine access controls within the FHA Catalyst modules that are dynamic, are tailored to user actions, and require continuous reauthentication to ensure that users have access only to information needed.

Housing should coordinate with HUD’s SOC to a. Ensure that FHA Catalyst user behavior monitoring logs are regularly captured and adequately reviewed for discrepancies in user activities. b. Establish program office responsibility for the log review process.